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Lemon Lane Fill Sampling PlanAugust 26, 1996 by U.S. Environmental Protection Agency Through the field sampling plan there are numerous references to the Lemon Lane Landfill being a large municipal landfill. Notwithstanding the word "landfill" in the site name, the site is actually a large dump where co-disposal of hazardous materials and municipal solid wastes occurred. The Lemon Lane Landfill is not distinguished from a dump by virtue of its design, construction, or management of the materials disposed there. In addition, the site is situated over a compound sinkhole, lending doubt about the stability of the site, and raising concerns about whether underlying native soil or waste materials can be wetted by subterranean drainage water during large storm events. Throughout the field sampling plan are references to "known" hot-spots. There are a number of guidance documents cited in the "References" list of the field sampling plan. In the field sampling plan you apparently rely on references for streamlining the fill sampling. I believe it is necessary to consider that: 1) the Lemon Lane Landfill is not an engineered landfill, as discussed above; and 2)that containment of PCBs at the site has not been and is not expected to be as simple a matter as capping the site. As you know, the site is already capped. From a review of historical PCB concentrations at the Illinois Central Spring, considering the concentration levels of PCBs in spring water before the cap was installed and also after the cap installation, one could argue that PCB concentrations at the spring have increased since the cap was installed in 1987. Certainly, the highest concentrations of PCBs in sediments at the Illinois Spring Stream (sufficient to cause two areas of the stream to be fenced) have been found approximately eight years after the cap was installed. Rather than focusing on streamlining investigations at the site, it is most appropriate to focus on what activities are necessary to mitigate the existing releases. The guidance document you refer to as "U.S. EPA 1991" provides a very good reference for the types of actions appropriate for the Lemon Lane Landfill. "U. S EPA 1991" contains a much more useful description for characterizing hot-spots. "U.S. EPA 1991" states that, "Hot-spots should be characterized if documentation and/or physical evidence exists to indicate the presence and approximate location of the hot-spots." Leave the word "known" out. Throughout the field sampling plan, there is reference to containment as the presumed remedy. Capping is not synonymous with containment. Containment refers to technologies that isolate the landfill contents and mitigate off-site migration through the use of engineering controls. Containment often includes capping, however, it may also require other controls (e.g. slurry walls, surface drainage controls, bottom liners, etc.). Section 1. Background and Summary of Sampling- Pg 4, 2nd P(aragraph) -It is unclear whether the rationale for a presumptive remedy of containment described in this paragraph is either the industry's standard, U S EPA's presumption, or Westinghouse belief. U. S. EPA considers that, in general, the remedial actions implemented at most CERCLA municipal landfill sites will include: containment of landfill contents remediation of hot spots control and treatment of contaminated and leachate, and control and treatment of landfill gas EPA's rationale for presuming containment at municipal landfill sites assumes that waste materials pose a relatively low low-level threat or where treatment is impracticable. For these sites, containment is identified as the most likely response because: 1) CERCLA municipal landfills are primarily composed of municipal, and to a lesser extent, hazardous wastes; therefore they often pose a low-level threat rather than a principal threat; and 2) the volume and heterogeneity of wastes within CERCLA municipal landfills will often make treatment impractical. The National Contingency Plan also contains an expectation that treatment should be considered for identifiable areas of highly toxic and/or mobile material (hot-spots) that pose potential principal threats, which do exist at the Lemon Lane Landfill. If you must portray EPA's rationale underlying its presumptive remedy as part of this field sampling plan, then I suggest that you also identify the types of sites that EPA considers appropriate for the presumptive remedy (i.e. CER -LA municipal landfills whose wastes pose a relatively low low-level threat), which incidently, does not describe the Lemon Lane Landfill. I suggest the following: U.S. EPA considers (use reference U.S. EPA 1991) that, in general, the remedial actions implemented at most CERCLA municipal landfill sites will include one or more nof the following actions: containment of landfill contents remediation of hot spots control and treatment of contaminated and leachate, and control and treatment of landfill gas Pg. 4, P3 4, 5, and 6 relate to why characterization of landfill wastes should not be conducted. These three paragraphs are irrelevant to the purpose or background for the sampling effort to be undertaken. Pg. 4, P 7, there is insufficient basis to determine the validity of the second sentence of this paragraph I believe that all of the parties acknowledge the view that ponded water in the area of monitoring well # 7 is related to elevated PCB concentrations found at Illinois Central Spring during storm events. Where in the landfill (or underneath the landfill) the water picks up the PCBs is not known. It is certainly possible that the ponded water ultimately contacts the PCB contaminated waste materials as the water moves toward the sinkhole. Whether fill material or PCBs from the fill material in the area of MOO-7 is ultimately carried to the spring with drainage water is not known. Pg. 4,P7, last sentence - leave out the entire sentence. This sentence is irrelevant to the purpose or background for the sampling effort to be undertaken. Pg. 4, P 8, this paragraph is sufficient for background related to the U.S. EPA sampling plans. Please eliminate the first sentence of the paragraph and replace it with the following, "During the course of discussions related to sampling the fill material at the site, the U. S. EPA proposed two different conceptual sampling plans." Pg. 5,P 1, eliminate the first two sentences. Begin the paragraph with, "This field sampling plan...." Pg. 5, 11 2, leave out the reference to "a single-phase field investigation". Westinghouse may wish to limit any investigation of the fill material, however, U.S. EPA will not agree to such a limitation up-front. Given the scope of the combined Westinghouse and U. S. EPA sampling effort, it may be that no further fill sampling is necessary. However, such a determination should be made only after an evaluation of the analytical data is performed. Section 2. Sample Network and Rational Sec. 2.1.2 - groundwater flows primarily to the Ill. Central Spring but not exclusively. Please reword so that it is clear that most of the uppermost groundwater flow eventually discharges to the Ill. Central Spring. Sec. 2.1.3 -there has been no evidence presented that the water in Sargent's pond drains slowly to the subsurface via small pores. Is this Westinghouse's speculation or is there information available to you that has not been presented in the technical meetings? If the description of Sargent's pond drainage is Westinghouse's belief, please identify it that way. Sec. 2.1.4 - what is meant by the immediate vicinity? Are you referring to the "catchment" area? This section does not account for the possibility that under some conditions some of the residential wells could get PCBs by the "ripping" of PCB containing water during certain high water events, potentially affecting residences outside of the "catchment" area. Also, this section should indicate the likelihood of environmental contamination, through the groundwater route, at Ill. Central Spring and potentially the Slaghterhouse spring. Sec. 2.1.5 - the description does not fully identify that capacitors were found in other areas of the site and that the limited sampling conducted in 1987 shows other potential hot-spot areas (exhibit#7 of the Consent Decree) Sec 2.1.6 - The last statement in the section is speculative and does not add value to the section. The pre-IRM samples were of soil not capacitor constituents. Does Westinghouse know whether the dump surface in the southwest corner of the landfill area was graded during the IRM activities? Unless there is specific information about soil removal or grading of the 1987 surface in the areas represented by the sample data, leave the statement out. Subsec. 2.1.6.1 - P 4- xylene at 36 ppm (locations 19 through 21) and 460 ppb dibenzofuran(locations 4, 5, and 10) was also reported by the TAT (refer to the March 11, 1987 TAT sampling attachment to your field sampling plan). P 5 - Does not report the values of City's dioxin data. Even if the data has quality control problems, the values should be reported and appropriately qualified. I understand that the City intentionally located "burn" areas of the fill and selected those areas to represent maximum dioxin/furan concentration in the fill. Simply stating that the lab reported major interferences that affected quantitation is too limited. S ubsec. 2.1.6.2 - Wasn't the purpose of the Westinghouse boring effort primarily to determine quantity of the fill material and BTU value of the waste material? The PCB sampling certainly was not done in areas where elevated PCB concentrations were expected. Subsec. 2.1.6.4 (pg 6) - Why hasn't any of the previous sampling results (prior to the last four quarters) been at least briefly described? At least a range of values should be reported here. The IDEM's sampling results of approximately 1995 for two of the monitoring wells should also be summarized here. Subsec. 2.1.6.4 (pg 7) - Tracer chemicals in storm water related to the site was shown to resurface at the Slaughterhouse Spring during an earlier tracer study. In fact, Westinghouse identified a "breakthrough" of tracer at Slaughterhouse. The last sentence of paragraph 3 of this section implies a more tentative conclusion. In the last paragraph of this section include that a low level of octa-dibenzofuran was also found in Il. Central sediment during the third quarter sampling. Also, earlier sampling by U. S. EPA found other chemicals (see Powell comment 8-2.1.6.4-10) in spring waters at the Il. Central Spring. Subsec. 2.1.6.5 - There should be included, in this discussion, that the boring locations identified in the sampling plan coincide with or are located near the EM survey anomalies. Subsec. 2.1.6.6 - Include that Earth Tech also provided an analysis of air photos. Section 2.1.7 -11 4 - Please describe how Westinghouse monitors gas emissions. Let people know ow you conclude that "the sampling results indicate that not gas emissions have been detected." In July 1991, EPA monitored PCB concentrations at the landfill perimeter and found PCBs in air (on a hot day) at 38 nanograms per cubic meter. This should be mentioned. Sec 2.1.8 - What is the point of the 1st sentence? As discussed in the general comments, the site is, more appropriately, a dump. P3 - Even if a 500 ppm value is chosen, there is at least one other potential hot-spot fitting the criteria of a 500 ppm concentration value. Both of the areas demonstrating elevated PCB concentrations (in excess of 500 ppm) were where piles of surface level capacitors were found. There were also other areas of the site where piles of surface level were found, but where sampling did not occur. The usage of "known" to describe hot-spots has been discussed in the general comment section of these comments. P 5 - What does the description "in the immediate vicinity of the site mean"? P 6 - this paragraph has no relevance to the sampling plan. Rather, this paragraph might possibly be relevant in a letter explaining why the company does not believe that additional sampling is necessary. The information gathered to date for this site (at least as is known to EPA) is not sufficient to examine the feasibility of removing PCB hot-spots from the landfill. On the other hand, if the company has information that describes the areal and vertical extent of contamination sufficient to describe hot-spots, it should come forward with that information. Perhaps, the company has presumed (as is indicated by the paragraph) that the sole remedy for this site is containment. U.S. EPA does not agree with that presumption. Also, as previously discussed, capping is not synonymous with containment. Therefore, the sampling described in this paragraph is not sufficient to support a remedy of containment. Section 2.2 - The first two paragraphs of this section are irrelevant to the purpose or objectives of the sampling to be undertaken. P 3 - The discussion concerning cancer slope factors is moot for the purpose of this plan. The comments concerning the possibility of changing threshold PCB concentrations based on new cancer slope factors are speculative and moot for the purpose of this sampling effort. P4 - The discussions provided in this paragraph have been previously discussed. Please remove the entire paragraph. P 5 - Because the author of this document has apparently not even referred to a dictionary definition for "remediated", let me offer a definition of "remedy": To restore to the natural or proper condition; put right. Covering over contaminated material is not synonymous with "remedy" or "remediated". Although restoration to the natural or proper condition may not be the criteria for a final remedy, it is likely that containment will be a component of a final remedy. A final remedy for this site may include capping, however, as previously discussed, capping is not synonymous with containment. Visual records and surface sampling have neither defined the approximate areal extent nor the vertical extent of PCB contamination. P 6 and 7 - These paragraphs are irrelevant to the objectives of this sampling plan. P 8 - the discussion of previous conceptual sampling plan has already been described. As a matter of fact, much of the information presented on this page has been repeated in (or reworded from)prior sections of the sampling plan. P 10 - One aspect of this plan has changed from a screening level sampling based on immuno-assay testing. By agreement with the other parties, the samples will now be analyzed by a laboratory. P 11 - The paragraph should be changed to reflect that U.S. EPA will samples from seven additional boring locations. P 12 - The paragraph should reflect the change in analytical protocol, discussed above. P 13 - Please include that Westinghouse will relocate the relocated U.S. EPA borings in the event that hand coring or power auger techniques do not provide samples down to the native soil. Section 2.3 - I recognize that Westinghouse does not, at least at this time, acknowledge responsibility for contaminants other than PCBs at the site. It is acceptable to describe that Westinghouse will limit its sampling to PCBs and the RCRA characteristic parameters, however, the responsibility for dioxins and furans remains an open question at this conjuncture. Section 2.4.2 - Compositing of the sinkhole samples (two 2 foot samples) is acceptable provided that the action level is halved. If the analytical results of any of the four foot composites exceed 250 ppm PCBs, then each of the 2 foot samples must be reanalyzed and the results reported. Section 2.4.3 - Same comment as for the sinkhole investigation (Section 2.4.2) Section 10.2 - Drill cuttings may be replaced with the borehole. Grouting of the bottom of the borehole may be required to prevent waste materials from being introduced below the current waste level. Suitable containers for storage of drill cuttings should be anticipated, however, in the event that not all of the waste material can be returned to the borehole. More specific protocol concerning grouting and containers will be provided at a later time. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2 ~ REGION 5 ~ WEST JACKSON BOULEVARD ~ CHICAGO, IL 60604-3590 BY TELEFAX October 3, 1996 Dorothy Alke, Director REPLY TO THE ATTENTION OF: Bloomington Project SR-6J Westinghouse Electric Corp. 11 Stanwix Street Pittsburgh, PA Dear Ms. Alke: By this letter, I am transmitting comments on the Westinghouse plan entitled Field Sampling Plan for the Fill Material at Lemon Lane Landfill dated August 21, 1996 and a nearly identical revision of the same sampling plan as revised on August 26, 1996 ("the plan"). Also transmitted with this letter are Earth Tech's comments on the plan, and Ida Levin's comments on the QAPP documents associated with the plan. Given the relatively short turnaround time requested for providing comments, I am sending the three sets of comments individually rather than consolidating them into one set of comments. In general, I appreciate the amount of work that you and your staff have done recently in attempting to resolve issues related to the fill sampling effort and in preparing the plans necessary to undertake the sampling effort. However, I am very disappointed with this particular field sampling plan. This plan is apparently an amalgam of sampling plan and Westinghouse position paper. I have taken considerable effort to review both the August 21, 1996 and August 26, 1996 documents and provide comments. In addition, U.S. EPA's contractor, Earth Tech, has also reviewed both documents and provided comments. Much of the effort that I have spent and the effort spent by Earth Tech has been in response to material that does not belong in a sampling plan. Now, in the late summer of this year, when available time for field work is very limited, and the parties are working to cooperate on a joint sampling effort, we receive a plan that requires excessive editing. I am aware that you would have provided a different, and I understand, less positional paper at least two weeks earlier, had the City not insisted on a public meeting to discuss issues related to the fill sampling. However, the time lost in your rewriting this plan and that time required to respond to it, places us perilously close to the end of good weather. I understand that you intend to submit a rewritten plan soon. I expect that we all will redouble our efforts to ensure that the fill sampling at Lemon Lane is undertaken this fall. I look forward to your cooperation in this effort. Sincerely, Dan Hopkins Remedial Project Manager |
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